CIT v. HDFC Bank Ltd.

366 ITR 505High Court2014#34 most cited

What is CIT v. HDFC Bank Ltd. authority for?

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

1,261

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v HDFC Bank Ltd · 366 ITR 505 · Section 14A disallowance · interest expenditure · exempt income · interest-free funds · own funds · presumption · sufficiency of funds · dividend income · Rule 8D

Also reported as

49 Taxmann.com 335226 Taxmann 132107 DTR 140

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 37(1)Section 36(1)(iii)Section 8DSection 10(34)Section 148

Issues it is cited on

disallowance of interest expendituredisallowance under section 14adisallowance u/s 14asection 14abook profitsrevenue expendituresection 115jsection 115jbsection 32capital expendituresection 37(1)section 36

Judgments citing CIT v. HDFC Bank Ltd.

Asst CIT CC 38, Mumbai vs. Uniphos Enterprises Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 3534/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…xempt income. Thus, no disallowance of interest expenses was warranted. To support her submissions the ld AR of the assessee also relied on the decision of Hon’ble Supreme Court in CIT Vs Reliance Industries Ltd (86 taxmann.com 24 SC), CIT Vs HDFC Bank Ltd (366 ITR 505 Bom), CIT vs Reliance Utilities and Power Ltd (313 ITR 414 SC) and assessees own case for AY 2000-01 in ITA No. 3456/Mum/2004. In alternative submissions, the ld AR of the assessee submits that the AO has to apply reasonable method for qutifying the expenditure attributable for earning exempt income. 21. On the other hand, the ld CIT-DR for th…

Addl CIT Cen RG IX, Mumbai vs. Uniphos Enterprises Ltd ( Formlery Known As United Phosphorus Ltd), Mumbai

In the result, the appeal of assessee is allowed

ITA 6236/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…xempt income. Thus, no disallowance of interest expenses was warranted. To support her submissions the ld AR of the assessee also relied on the decision of Hon’ble Supreme Court in CIT Vs Reliance Industries Ltd (86 taxmann.com 24 SC), CIT Vs HDFC Bank Ltd (366 ITR 505 Bom), CIT vs Reliance Utilities and Power Ltd (313 ITR 414 SC) and assessees own case for AY 2000-01 in ITA No. 3456/Mum/2004. In alternative submissions, the ld AR of the assessee submits that the AO has to apply reasonable method for qutifying the expenditure attributable for earning exempt income. 21. On the other hand, the ld CIT-DR for th…

Uniphos Enterprises Ltd ( Formerly Known As United Phosphorus Ltd), Mumbai vs. Addl CIT Cen RG IX, Mumbai

In the result, the appeal of assessee is allowed

ITA 6224/MUM/2010[2003-04]Status: DisposedITAT Mumbai30 May 2025AY 2003-04

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…xempt income. Thus, no disallowance of interest expenses was warranted. To support her submissions the ld AR of the assessee also relied on the decision of Hon’ble Supreme Court in CIT Vs Reliance Industries Ltd (86 taxmann.com 24 SC), CIT Vs HDFC Bank Ltd (366 ITR 505 Bom), CIT vs Reliance Utilities and Power Ltd (313 ITR 414 SC) and assessees own case for AY 2000-01 in ITA No. 3456/Mum/2004. In alternative submissions, the ld AR of the assessee submits that the AO has to apply reasonable method for qutifying the expenditure attributable for earning exempt income. 21. On the other hand, the ld CIT-DR for th…

The ACIT CC-38, Mumbai vs. M/S. United Phosphorous Ltd, Mumbai

In the result, the appeal of assessee is allowed

ITA 1822/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…xempt income. Thus, no disallowance of interest expenses was warranted. To support her submissions the ld AR of the assessee also relied on the decision of Hon’ble Supreme Court in CIT Vs Reliance Industries Ltd (86 taxmann.com 24 SC), CIT Vs HDFC Bank Ltd (366 ITR 505 Bom), CIT vs Reliance Utilities and Power Ltd (313 ITR 414 SC) and assessees own case for AY 2000-01 in ITA No. 3456/Mum/2004. In alternative submissions, the ld AR of the assessee submits that the AO has to apply reasonable method for qutifying the expenditure attributable for earning exempt income. 21. On the other hand, the ld CIT-DR for th…

M/S. United Phosphorus Ltd(Now Known As Uniphos Enterprises Ltd), Mumbai vs. The DCIT Cen Cir-38, Mumbai

In the result, the appeal of assessee is allowed

ITA 1787/MUM/2006[2002-2003]Status: DisposedITAT Mumbai30 May 2025AY 2002-2003

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 254(1)Section 271(1)(c)Section 37(1)Section 80

…xempt income. Thus, no disallowance of interest expenses was warranted. To support her submissions the ld AR of the assessee also relied on the decision of Hon’ble Supreme Court in CIT Vs Reliance Industries Ltd (86 taxmann.com 24 SC), CIT Vs HDFC Bank Ltd (366 ITR 505 Bom), CIT vs Reliance Utilities and Power Ltd (313 ITR 414 SC) and assessees own case for AY 2000-01 in ITA No. 3456/Mum/2004. In alternative submissions, the ld AR of the assessee submits that the AO has to apply reasonable method for qutifying the expenditure attributable for earning exempt income. 21. On the other hand, the ld CIT-DR for th…

Asst. Commissioner of Income Tax 8(2)(1) Mumbai, Mumbai vs. Ms. Piramal Enterprises Limited, Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2589/MUM/2024[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

…) r.w.s. 254 deleted the disallowance under Rule 8D(2)(ii) of the Rules. Assessee also relied upon the decision in the case of South Indian Bank Ltd. vs. CIT (438 ITR 1)(SC). Godrej & Boyce Mfg. Co. Ltd. vs. DCIT (328 ITR 81) (Bom HC), HDFC Bank Ltd. vs. CIT (366 ITR 505) (Bom HC), CIT vs. Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient interest free funds to mak…

Piramal Enterprises Limited, Mumbai vs. The Assistant Commissioner of Income Tax Circle 7(3)(2), Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2588/MUM/2024[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

…) r.w.s. 254 deleted the disallowance under Rule 8D(2)(ii) of the Rules. Assessee also relied upon the decision in the case of South Indian Bank Ltd. vs. CIT (438 ITR 1)(SC). Godrej & Boyce Mfg. Co. Ltd. vs. DCIT (328 ITR 81) (Bom HC), HDFC Bank Ltd. vs. CIT (366 ITR 505) (Bom HC), CIT vs. Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient interest free funds to mak…

Piramal Enterprises Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 8(2)(1), Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2584/MUM/2024[2009-10]Status: DisposedITAT Mumbai21 May 2025AY 2009-10

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

…) r.w.s. 254 deleted the disallowance under Rule 8D(2)(ii) of the Rules. Assessee also relied upon the decision in the case of South Indian Bank Ltd. vs. CIT (438 ITR 1)(SC). Godrej & Boyce Mfg. Co. Ltd. vs. DCIT (328 ITR 81) (Bom HC), HDFC Bank Ltd. vs. CIT (366 ITR 505) (Bom HC), CIT vs. Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient interest free funds to mak…

Piramal Enterprises Limited, Mumbai vs. The Deputy Commissioner of Income Tax, Circle 8(2)(1), Mumbai

In the result, all the three appeals of the assessee are partly allowed and appeal of the Revenue is dismissed

ITA 2582/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 May 2025AY 2010-11

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Ronak Doshi, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 115JSection 143(3)Section 14ASection 80Section 80I

…) r.w.s. 254 deleted the disallowance under Rule 8D(2)(ii) of the Rules. Assessee also relied upon the decision in the case of South Indian Bank Ltd. vs. CIT (438 ITR 1)(SC). Godrej & Boyce Mfg. Co. Ltd. vs. DCIT (328 ITR 81) (Bom HC), HDFC Bank Ltd. vs. CIT (366 ITR 505) (Bom HC), CIT vs. Reliance Utilities & Power Ltd. (313 ITR 340) (Bom HC) and other decisions. Thus, assessee submitted that no disallowance u/s 14A r.w.r. 8D(2)(ii) should be made. 7.3. Tribunal had set aside the issue to the file of ld. Assessing Officer for limited purpose of verifying the availability of sufficient interest free funds to mak…

Aon Consulting Private Limited, New Delhi vs. DCIT, Circle-1(1), Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 739/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kediaआअसं.739/िद"ी/2022(िन.व. 2017-18) M/S Aon Consulting P. Ltd., Aon Centre, 9Th To 11Th, Building No.2, Unitech Realty Projects Ltd., (Sez), Village Tikri, Sector 48, Gurgaon, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aahca-0739-J बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 1(1), Delhi Assessee By : Shri Darpan Kirpalani, Advocate Department By : S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 17/01/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 09/04/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed The Assessment Order Dated 22.02.2022 Passed U/S. 143 R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Assessee In Appeal Has Assailed Transfer Pricing Adjustment Made In Respect Of Software Development Services Segment. The Assessee Has Also Assailed Some Additions On Corporate Issue, Viz. Disallowance Made U/S. 14A R.W.S. 8D & Additions Based On Intimation U/S. 143(1) Of The Act.

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. DR
Section 143Section 143(1)Section 14A

…uo-moto disallowance of Rs.14,14,000/- and no borrowed were utilized by the assessee for making investments in Mutual Funds. Hence, the case of the assessee is squarely covered by the decision of Hon’ble Bombay High Court in the case of CIT vs. HDFC Bank Ltd. 366 ITR 505 (Bom.) 15 13. The ld. DR has not disputed the fact that borrowed funds are not utilized for making investments and no exempt income has been earned by the assessee on investment made in subsidiary companies. However, the ld. DR vehemently supported the impugned order and prayed for dismissing ground no. 4 to 7 of appeal. The ld. DR submits that…

O E N India Limited, Kochi vs. DCIT, Corporate Cir 2(1), Kochi

In the result, ground No.2 filed by the assessee stands allowed

ITA 861/COCH/2023[2018-19]Status: DisposedITAT Cochin08 Apr 2025AY 2018-19

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Radhesh Bhatt, CAFor Respondent: Smt.Leena Lal, Sr.AR
Section 10Section 10(1)Section 143(3)Section 14ASection 250Section 40

….14A r.w. Rule 8D(2) is called for. In support of this contention, he filed a chart at page 4 and 5 of the written submission, and prayed that no disallowance of interest is called for. Reliance is placed on the following decisions, i.e., (i) CIT v. HDFC Bank 366 ITR 505 (Bombay), (ii) Premier Finance & Trading Co. Ltd. (104 Taxmann.com 97 (Bom HC), and (iii) Ashok Apparels 106 Taxmann.com 63 (Bom.) 4 ITA Nos.859-861/Coch/2023. OEN India Limited. 7. As regards the disallowance under clause (3) of Rule 8D, it is submitted that application of Rule 8D is not automatic and AO cannot be resorted to the disallowance w…

O E N India Limited, Kochi vs. ITO Corporate Ward-2(2), Kochi

In the result, ground No.2 filed by the assessee stands allowed

ITA 860/COCH/2023[2016-17]Status: DisposedITAT Cochin08 Apr 2025AY 2016-17

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Radhesh Bhatt, CAFor Respondent: Smt.Leena Lal, Sr.AR
Section 10Section 10(1)Section 143(3)Section 14ASection 250Section 40

….14A r.w. Rule 8D(2) is called for. In support of this contention, he filed a chart at page 4 and 5 of the written submission, and prayed that no disallowance of interest is called for. Reliance is placed on the following decisions, i.e., (i) CIT v. HDFC Bank 366 ITR 505 (Bombay), (ii) Premier Finance & Trading Co. Ltd. (104 Taxmann.com 97 (Bom HC), and (iii) Ashok Apparels 106 Taxmann.com 63 (Bom.) 4 ITA Nos.859-861/Coch/2023. OEN India Limited. 7. As regards the disallowance under clause (3) of Rule 8D, it is submitted that application of Rule 8D is not automatic and AO cannot be resorted to the disallowance w…

O E N India Limited, Kochi vs. ACIT Corporate Circle-2(1), Kochi

In the result, ground No.2 filed by the assessee stands allowed

ITA 859/COCH/2023[2012-13]Status: DisposedITAT Cochin08 Apr 2025AY 2012-13

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Radhesh Bhatt, CAFor Respondent: Smt.Leena Lal, Sr.AR
Section 10Section 10(1)Section 143(3)Section 14ASection 250Section 40

….14A r.w. Rule 8D(2) is called for. In support of this contention, he filed a chart at page 4 and 5 of the written submission, and prayed that no disallowance of interest is called for. Reliance is placed on the following decisions, i.e., (i) CIT v. HDFC Bank 366 ITR 505 (Bombay), (ii) Premier Finance & Trading Co. Ltd. (104 Taxmann.com 97 (Bom HC), and (iii) Ashok Apparels 106 Taxmann.com 63 (Bom.) 4 ITA Nos.859-861/Coch/2023. OEN India Limited. 7. As regards the disallowance under clause (3) of Rule 8D, it is submitted that application of Rule 8D is not automatic and AO cannot be resorted to the disallowance w…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 454/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…est on such borrowed funds is to be disallowed under Section 14A. The Court further held that Rule 8D, which prescribes the method for computing disallowance, applies where the direct identification of expenditure is not possible. CIT v. HDFC Bank Ltd. (2014) 366 ITR 505 (SC): The Supreme Court emphasized that the disallowance under Section 14A applies even if the income from the investment is not received during the relevant assessment year. The Court also stated that it is not necessary for the Assessing Officer to demonstrate a direct nexus between the borrowed funds and the exempt income; rather, the onus is…

ACIT, Range-I, Lucknow vs. M/S Apco Infratech Pvt. Ltd., Lucknow

ITA 453/LKW/2020[2016-17]Status: DisposedITAT Lucknow02 Apr 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…est on such borrowed funds is to be disallowed under Section 14A. The Court further held that Rule 8D, which prescribes the method for computing disallowance, applies where the direct identification of expenditure is not possible. CIT v. HDFC Bank Ltd. (2014) 366 ITR 505 (SC): The Supreme Court emphasized that the disallowance under Section 14A applies even if the income from the investment is not received during the relevant assessment year. The Court also stated that it is not necessary for the Assessing Officer to demonstrate a direct nexus between the borrowed funds and the exempt income; rather, the onus is…

M/S. Apco Infratech Pvt. Ltd., Lucknow vs. ACIT-I, Lucknow

In the result, appeals vide I

ITA 357/LKW/2020[2017-18]Status: DisposedITAT Lucknow02 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(1)Section 143(2)Section 143(3)Section 80I

…st on such borrowed funds is to be disallowed under Section 14A. The Court further held that Rule 8D, which prescribes the method for computing disallowance, applies where the direct identification of expenditure is not possible. CIT v. HDFC Bank Ltd. (2014) 366 ITR 505 (SC): The Supreme Court emphasized that the disallowance under Section 14A applies even if the income from the investment is not received during the relevant assessment year. The Court also stated that it is not necessary for the Assessing Officer to demonstrate a direct nexus between the borrowed funds and the exempt income; rather, the onus is…

Pawan Tradecorp Private Limited, Dhar vs. ACIT-4(1), Indore

In the result appeal of the assessee is partly allowed

ITA 644/IND/2024[2016-17]Status: DisposedITAT Indore27 Feb 2025AY 2016-17

Bench: Shri Manish Boradpawan Tradecorp Private Acit 4(1), Limited, Indore Khandelwal Complex, Dhar Road, Vs. Manawar, Dist. Dhar Dhar (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadcp6640D Assessee By Ms. Nisha Lahoti, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 27.02.2025 Date Of Pronouncement 27.02.2025 O R D E R

Section 143(3)Section 14A

…vestment. For this proposition she referred and relied to many decisions including that of Hon’ble Bombay High 2 Pawan Tradecorp Private Limited– A.Y 2016-17 Court in case of CIT v. Reliance Utilities & Power Ltd 313 ITR and that in case of CIT V/s HDFC Bank 366 ITR 505. 5. On the other hand Ld. Departmental Representative supported the orders of the lower authorities. 6. I have heard rival contentions and perused the records before me. The assessee is a Private Limited company and income of Rs.31,61,660/- declared in the e-return for Assessment Year 2016- 17 filed on 29.09.2016. In the assessment proceeding…

ACIT-Central Circle -2(1), Nagpur vs. Shri Nandkumar Khattumal Harchandani, Nagpur

In the result, appeal of the Revenue stands dismissed

ITA 411/NAG/2019[2015-16]Status: DisposedITAT Nagpur25 Feb 2025AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 10(38)Section 68

…by the jurisdictional High Court of Bombay. Once the surplus/interest free funds are excess of investment made, then in view of the ratio and principle laid down by Hon‟ble Bombay High Court in Reliance Utilities (2009) 313 ITR 340 (Bom) and HDFC Bank (2014) 366 ITR 505 (Bom) as relied upon by the Ld. Counsel, no disallowance under section 14A on account of interest expenditure should be made. Their Lordships have clearly opined that, once in the Balance Sheet, the assessee has reflected surplus/own funds and also interest bearing funds, then presumption is that, investments must have been made out of interest f…

Assistant Commissioner of Income Tax 3(4), Mumbai, Aaykar Bhavan vs. Idbi Bank Ltd, Parth Plazamorbi

In the result, all the aforesaid appeals of the Revenue and CO of the assessee are dismissed

ITA 5959/MUM/2024[2013-14]Status: DisposedITAT Mumbai24 Feb 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Vs. Idbi Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024) Assessment Year: 2013-14 Idbi Bank Ltd., Vs. Assistant Commissioner Apulki Cornermenon, Of Income Tax -3(4), Piston Compound, Mumbai Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent)

For Appellant: Shri C. Naresh, ARFor Respondent: Shri R.A. Dhyani, CIT,DR
Section 250

…d as deduction. Further the treatment is also in accordance with CBDT instruction no. 17 dated 26.11.2008 which is binding on the department.This issue has been decided in favour of the assessee by Jurisdictional High Court of Bombay in the case of HDFC Bank (366 ITR 505). Further,this issue was specifically decided in favour of the assessee by the co-ordinate bench in ITA Nos. 2937 and 2919/Mum/20222 and 5250/Mumb/2024 and also for AY 2017-18 in ITA 2937/MUM/2022 & CO.No.28/Mum/2024 IDBI Bank Ltd. 2919/MUM/2022 dated May 11, 2023. The ld.CIT,DR vide has relied on the assessment order. 7. Respectfully following t…

Assistant Commissioner of Income Tax 3(4), Mumbai vs. Idbi Bank Ltd, Panchanantala Road

In the result, all the aforesaid appeals of the

ITA 5958/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Feb 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ष / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Income Tax -3(4), Mumbai Vs. Idbi Bank Ltd., Apulki Cornermenon, Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलार्थी/Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024)

For Respondent: Shri C. Naresh, AR
Section 250

…as deduction. Further the treatment is also in accordance with CBDT instruction no. 17 dated 26.11.2008 which is binding on the department. This issue has been decided in favour of the assessee by Jurisdictional High Court of Bombay in the case of HDFC Bank (366 ITR 505). Further,this issue was specifically decided in favour of the assessee by the co-ordinate bench in ITA Nos.2937 and 2919/Mum/20222 and 5250/Mumb/2024 and also for AY 2017-18 in ITA 2937/MUM/2022 & 2919/MUM/2022 dated May 11, 2023. The ld.CIT,DR vide has relied on the assessment order. 7. Respectfully following the above decision on identical fac…